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The Resource Aligning transfer pricing outcomes with value creation, Actions 8-10 - 2015 final reports

Aligning transfer pricing outcomes with value creation, Actions 8-10 - 2015 final reports

Label
Aligning transfer pricing outcomes with value creation, Actions 8-10 - 2015 final reports
Title
Aligning transfer pricing outcomes with value creation, Actions 8-10 - 2015 final reports
Subject
Language
  • eng
  • eng
Summary
This work on transfer pricing under the BEPS Action Plan has focused on three key areas. Work under Action 8 looked at transfer pricing issues relating to transactions involving intangibles, since misallocation of the profits generated by valuable intangibles has contributed to base erosion and profit shifting. Work under Action 9 considered the contractual allocation of risks, and the resulting allocation of profits to those risks, which may not correspond with the activities actually carried out. Work under Action 9 also addressed the level of returns to funding provided by a capital-rich MNE group member, where those returns do not correspond to the level of activity undertaken by the funding company. Work under Action 10 focused on other high-risk areas, including the scope for addressing profit allocations resulting from transactions which are not commercially rational for the individual enterprises concerned (re-characterisation), the scope for targeting the use of transfer pricing methods in a way which results in diverting profits from the most economically important activities of the MNE group, and neutralising the use of certain types of payments between members of the MNE group (such as management fees and head office expenses) to erode the tax base in the absence of alignment with value creation. The work under Actions 8-10 of the BEPS Action Plan will ensure that transfer pricing outcomes better align with value creation of the MNE group. Moreover, the holistic nature of the BEPS Action Plan will ensure that the role of capital-rich, low-functioning entities in BEPS planning will become less relevant. As a consequence, the goals set by the BEPS Action Plan in relation to the development of transfer pricing rules have been achieved without the need to develop special measures outside the arm's length principle. Further work will be undertaken on profit splits and financial transactions. Special attention is given in the Report to the needs of developing countries. This new guidance will be supplemented with further work mandated by the G20 Development Working Group, following reports by the OECD on the impact of base erosion and profit shifting in developing countries. Finally, the interaction with Action 14 on dispute resolution will ensure that the transfer pricing measures included in this Report will not result in double taxation
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
Series statement
OECD/G20 Base Erosion and Profit Shifting Project
Series volume
Action 8-10: 2015 final reports
http://library.link/vocab/subjectName
  • OECD
  • OECD Transfer Pricing Guidelines
  • BEPS Project (OECD)
  • transfer pricing
  • value creation
  • transactional profit methods
  • intangibles
  • risk
  • cost contribution arrangement
  • developing countries
Label
Aligning transfer pricing outcomes with value creation, Actions 8-10 - 2015 final reports
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/OECD/Aligning_transfer_pricing_outcomes_with_value_creation.zip
Instantiates
Publication
Extent
186 p.
Isbn
9789264241237
Isbn Type
(print)
Issn
  • 2313-2604 (print)
  • 2313-2612 (online)
Note
20151008
Label
Aligning transfer pricing outcomes with value creation, Actions 8-10 - 2015 final reports
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/OECD/Aligning_transfer_pricing_outcomes_with_value_creation.zip
Publication
Extent
186 p.
Isbn
9789264241237
Isbn Type
(print)
Issn
  • 2313-2604 (print)
  • 2313-2612 (online)
Note
20151008

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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